In the case of Anant Chintaman Lagu vs The State Of Bombay, which was decided on 14th December 1959, the Supreme Court of India was faced with a complex case of murder by alleged poisoning. The case was unique in that the autopsy and chemical analysis failed to disclose any poison in the body of the deceased, Laxmibai Karve. However, the court held that the death by poisoning could be proven by circumstantial evidence, particularly the conduct of the accused, both before and after the incident.
Facts of the Case
Laxmibai Karve was a resident of Poona, who had contracted tuberculosis after the birth of her son, Purushottam, and had suffered from diabetes since 1946. She was under the medical care of the appellant, Anant Chintaman Lagu, who was also a close family friend. In 1955, Lagu started living in the main room of the suite occupied by Laxmibai and was managing her affairs.
On the night of November 12, 1956, Laxmibai and Lagu left Poona for Bombay for a medical consultation. Upon arrival in Bombay, Laxmibai was unconscious and was admitted to the G.T. Hospital, where she died at 11:30 a.m. without regaining consciousness. Her body remained at the hospital until it was sent to the J. J. Hospital morgue for preservation. It was here that a suspicious ligature mark on the neck was noticed, leading to a postmortem examination and chemical analysis of the viscera. Both the autopsy and the chemical analysis failed to disclose any poison, and the mark on the neck was found to be postmortem.
Issues and Court’s Observations
The court had to determine whether Laxmibai’s death was a result of poisoning, despite the absence of any detectable poison in her body. The court relied heavily on circumstantial evidence, particularly the conduct of Lagu, both before and after Laxmibai’s death. The court noted that Lagu, who was Laxmibai’s medical adviser, had gradually ingratiated himself into her good opinions, managed her affairs, and had even forged her signature on a dividend warrant. After her death, he abandoned her body at the hospital, spread the story that she was alive, and misappropriated all her properties.
Ruling
The court held that even though the cause of death may not appear to be established by direct evidence, the medical evidence of experts and the circumstances of the case may be sufficient to infer that the death must be the result of the administration to the victim of some unrecognised poison or drug which acts as a poison. The court concluded that the appellant’s conduct unerringly pointed to the conclusion that the death of the deceased was the result of the administration of some unrecognised poison or drug which would act as a poison and that the appellant was the person who administered it. As a result, Anant Chintaman Lagu was convicted of murder under s. 302 of the Indian Penal Code, and his sentence of death was confirmed by the Bombay High Court.